Renico v. Lett
Issues
Does a trial court judge’s decision to declare a mistrial after the jury foreman stated that the jurors were not going to be able to reach a unanimous verdict violate double jeopardy?
Reginald Lett was convicted of second-degree murder in a Michigan state court in his second trial for the same offense. In his first trial, the judge determined that the jury was deadlocked and declared it a mistrial. Lett then filed a petition for a writ of habeas corpus in the Federal District Court for the Eastern District of Michigan. His petition was granted. On appeal, the Sixth Circuit Court of Appeals affirmed the district court’s ruling on the basis that Lett’s Fifth Amendment right to be free from Double Jeopardy had been violated because the trial court had not used “sound discretion” in finding a “manifest necessity” to declare a mistrial and terminate the ongoing proceedings. This case presents the Supreme Court with the opportunity to clearly articulate what state courts must do before declaring a mistrial to avoid running afoul of the Fifth Amendment.
Questions as Framed for the Court by the Parties
Whether the United States Court of Appeals for the Sixth Circuit, in a habeas case, erred in holding that the Michigan Supreme Court failed to apply clearly established Supreme Court precedent under 28 U.S.C. § 2254 in denying relief on double jeopardy grounds in the circumstance where the State trial court declared a mistrial after the foreperson said that the jury was not going to be able to reach a verdict.
Reginald Lett was convicted for the shooting death of Adesoji Latona at a liquor store in Detroit, Michigan on August 29, 1996. See Lett v. Renico, 507 F.Supp.2d 777, 779 (E.D. Mich.
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Additional Resources
· Wex: Habeas Corpus
· Wex: Double Jeopardy
· Wex: Fifth Amendment
· CRS Annotated Constitution: Reprosecution Following Mistrial